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PHASE 1 BOND RELEASE PRELIMINARY REVIEW <br />Under Items 7 and l5, the overland conveyor is listed as one of the loptrons for which Phase 1 <br />bond release is requested. While it is We that along much of its length, the conveyor has been <br />dismantled and removed, the concrete footers are still intact and the conveyor corridor has not <br />been graded. Pursuant to Rule 3.03.1(2)(b), initial phase bond release is to be granted oNy upon <br />successful completion of backfilling and grading. Therefore, the Division cannot at this time grant <br />partial bond release for conveyor reclamation, and reference to the overland conveyor as one of <br />the areas for which bond release is requested should be deleted from the application. <br />2. Also under Item 7, the Northwest Intake Portal is not listed, but this facility is listed under Item <br />15. L`the Northwest Intake Portal is one of the locations requested for release, it should be listed <br />under both items. <br />3. Items I 1 and 121ist, respectively, the original total bond amount (for the area requested for <br />release), and the dollar amount requested for release. Because only certain portions of the permit <br />area are being requested for release, it is not entirely clear how the dollar amounts were derived. <br />Please provide some elaboration and documentation far the referenced amounts. <br />4. Based on review of the land ownership map in the permit, it would appeaz that the Colorado <br />Department of Transportation and the D&RGW should be sent copies of the notice of bond <br />release. Please ensue Utat these entities are notified and include certification of mailing with the <br />amended application <br />5. On the CRDA #1 and #2 Map submitted with the application, please delineate the specific areas <br />for which Phase 1 bond release is requested, so that srch areas are clearly distinguished from areas <br />to be excluded. Areas of bare refuse, temporary roads, drainage/sediment control structures, and <br />areas subject to future disturbance would be excluded. <br />6. On the North Decline Map, please clearly delineate bond release request areas to distinguish from <br />excluded areas. Excluded areas would include sedimenUdrainage control swaures, and any areas <br />subject to future disturbance, such as proposed disturbances associated with the TR-33 mine de- <br />wa[eringplan Similar inclusion boundaries should be included on the 2 West Portals Map and the <br />Roadside Mine South Fan installation Map. <br />7. For the South Lease exploration sites and roads, please provide a location map delineating areas <br />subject to the bond release request (with drill hole designations). Also, for the drill holes, please <br />provide appropriate abandonment reports or appropriate documentation that wells were properly <br />sealed. Finally, for Ute drill pads and roads, please discuss the extent and success of reclamation <br />with respect to permit and regulatory requirements, and postmine land use/landowner <br />considerations. In responding to this issue, please refer to comments listed in the Division's <br />inspection report of July 16, 1997, and the January 7, 19981etter from Catherine Robertson of the <br />BLM Grand Junction Resource Area to Larry Reschke of Powderhom Coal Company. <br />8. For reclaimed refuse pile areas, please provide compliance documentation including approved and <br />existing typical cross-sections and documentation of non-toxic cover replacement Also, please <br />provide or reference appropriate documentation regarding underdrain installation, piezometric <br />monitoring, construction and compaction compliance, lability, drainage/sediment control, and <br />perimeter ditch and upland diversion wnstruaion and functioning. <br />9. For the South Farb 2 Wes[ Portals, and North Decline sites, please provide certified as built <br />topographic contours and representative cross sections to allow for comparison with approved <br />designs. Also, please provide documentation including certified cross sections and profiles, and <br />other information as appropriate, to demonstrate that permanent drainage channels at the Nortlt <br />